Sanction and Export Control Laws | Applicability by Country
Last updated: 23 February 2021
Certain countries are subject to either Comprehensive Sanctions, List-Based Sanctions or Targeted Sanctions. Comprehensive sanctions prohibit virtually ALL exports/imports and other transactions without a license or other U.S. Government authorization.
In addition, certain organizations and individuals may be subject to trade sanctions, embargoes, and other restrictions by law and these are referred to as List-Based Sanctions. These restrictions apply to all IEEE activities. IEEE’s process for Denied Parties Vetting will permit you to quickly check and document whether a person or an organization is a Denied party.
If you intend to travel on IEEE business to, ship or transact with any country that that is identified on the Comprehensively Sanctioned Country lists below, you MUST contact firstname.lastname@example.org for guidance. Because of the complex trade regulations governing these countries, as well as the severe civil and criminal penalties that could be levied for sanctions violations, members, volunteers and staff should not attempt to interpret the Sanction Laws on their own.
There are five major country-based sanctions programs currently in effect, broadly regulating nearly all transactions with:
Almost all transactions with these jurisdictions are prohibited.
In addition, Venezuela and Sudan each are subject to multiple sanctions programs, but the Venezuelan and Sudanese people are not subject to comprehensive U.S. Sanctions.
In late 2020, the Sudan Sanctions were lifted. There are still individuals or entities in that country that may be subject to targeted sanctions or on the SDN and so vetting needs to be conducted. NOTE: The South Sudan Sanctions Program (SSSP) remains in effect.
The use List-Based or Targeted Sanctions has allowed the U.S. government to more precisely target persons and groups who pose a threat to national security, foreign policy, and economy of the United States. This lists are sometimes referred to as Denied Party or Restricted Party Lists. Individuals in these countries or who may reside other countries can appear on these lists. IEEE's policy is to vet all individuals and entities in the country below to identify any potential red flags. This ensures that appropriate due diligence is conducted before we enter into any transaction or relationship that might otherwise violate sanction or export control regulations.
*Programs against Côte d’Ivoire, Liberia, and Myanmar became inactive within last few years but certain individuals/entities still targeted within those countries
The SDN includes individuals and entities owned or controlled by, or acting for or on behalf of, targeted countries. It also lists individuals, groups, and entities, such as terrorists and narcotics traffickers designated under programs that are not country-specific. Collectively, such individuals and companies are called "Specially Designated Nationals" or "SDNs." Their assets are blocked and U.S. persons are generally prohibited from dealing with them.
The BIS Entity List includes the names of certain foreign persons – including businesses, research institutions, government and private organizations, individuals, and other types of legal persons – that are subject to specific license requirements for the export, re-export and/or transfer (in-country) of specified items. In many instances these include academies, university, educational and research institutions. Parties whose presence in a transaction can trigger a license requirement supplemental to those elsewhere in the Export Administration Regulations (EAR). The list specifies the license requirements and policy that apply to each listed party.
The BIS Unverified List includes individuals and entities ineligible to receive items subject to the Export Administration Regulations (EAR) by means of a license exception. In many instances these include academies, university, educational and research institutions.The presence of a party on this list in a transaction is a “Red Flag” that should be resolved before proceeding with the transaction.
US Department of Treasury/OFAC: Foreign Sanction Evaders List (FSE) includes foreign individuals and entities determined to have violated, attempted to violate, conspired to violate, or caused a violation of U.S. sanctions on Syria or Iran. It also lists foreign persons who have facilitated deceptive transactions for or on behalf of person(s) subject to U.S. sanctions. Collectively, such individuals and companies are called “Foreign Sanctions Evaders” or “FSEs.” Transactions by U.S. persons or within the U.S. involving FSEs are prohibited.
US Department of Commerce/Bureau of Industry and Security (BIS): Denied Persons List includes people and companies whose export privileges have been denied by BIS. A U.S. company or individual may not participate in an export transaction with an individual or company on the Denied Persons List.
There are additional U.S. Denied Party Lists as well as lists in each of the countries which has it owns autonomous sanctions regime or which implements and enforces UN sanctions